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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ9169097 (MF) ADJ9165067
Regular
Aug 09, 2019

Rosa Reyes vs. Nestle USA, ACE American Insurance

This case involved lien claimants whose liens were disallowed because their Labor Code section 4903.8(d) declarations were signed with electronic "S" signatures rather than wet signatures. The Workers' Compensation Appeals Board (WCAB) granted reconsideration, holding that electronic signatures are valid for these declarations. The WCAB found that existing law and prior panel decisions support the use of electronic signatures, aligning with the Uniform Electronic Transactions Act. The matter was returned to the trial level for further proceedings consistent with this ruling.

Labor Code section 4903.8(d)wet signatureelectronic signaturelien claimantsJoint Findings of Fact and OrderElectronic Adjudication Management SystemJET File Business RulesEAMS Rulespenalty of perjuryUniform Electronic Transactions Act
References
Case No. ADJ2432526 (MON 0226419)
Regular
May 07, 2012

PATRICIA MANDEL vs. MEDIA SERVICES, INC., CALIFORNIA INSURANCE GUARANTEE ASSOCIATION

This case concerns CIGA's challenge to a WCJ's order allowing an applicant, who relocated to Connecticut, to testify via remote deposition regarding out-of-pocket expenses for an admitted industrial injury. CIGA argued this would cause prejudice and irreparable harm. The Appeals Board denied CIGA's petition for removal, adopting the WCJ's reasoning that remote depositions are permissible under California law. The Board affirmed the WCJ's decision to proceed with the applicant's deposition and consider cost reimbursement.

CIGAPetition for RemovalOff CalendarOut-of-State DepositionLabor Code § 5811Agreed Medical EvaluatorKnee ReplacementIndustrial InjuryRemote Electronic MeansCalifornia Code of Civil Procedure § 2025.310
References
Case No. ADJ17371801; ADJ18218517
Regular
Oct 10, 2025

MARIO PALACIOS vs. PLAN B ADVANTAGE, INC.; STATE COMPENSATION INSURANCE FUND

Applicant Mario Palacios petitioned for removal from a WCJ's order mandating in-person appearances for himself and two witnesses to verify signatures on a Compromise and Release (C&R). He also sought clarification on electronic signatures and challenged a prior C&R disapproval. The Workers' Compensation Appeals Board granted the petition for removal, rescinding the August 4, 2025 order and allowing Palacios to appear remotely to verify his signature. The Board declined to issue an advisory opinion on electronic signatures but referenced relevant codes, and deemed the challenge to the prior C&R disapproval moot due to an amended C&R.

Petition for RemovalCompromise and ReleaseElectronic SignaturesIn-Person HearingRemote AppearanceDue ProcessWCJ OrderRescind OrderGood CauseWitness Testimony
References
Case No. ADJ9921643
Regular
Jul 09, 2019

Katherine Turner vs. CITY OF CULVER CITY

The Workers' Compensation Appeals Board granted reconsideration of a decision that deemed lien claims invalid due to electronic signatures on declarations. The Board found that electronic signatures, specifically the "S signature" format used in electronic filings, are legally sufficient under the Uniform Electronic Transactions Act. Consequently, the prior decision invalidating the liens based on the lack of a "wet" signature was rescinded, and the case was returned for further proceedings. The Board clarified that electronic signatures satisfy the requirements of Labor Code section 4903.8(d) declarations.

Labor Code section 4903.8(d)electronic signaturewet signaturepenalty of perjurylien claimantWorkers' Compensation Appeals BoardOpinion and Order Granting Petition for Reconsiderationfindings of fact and ordersadministrative law judgeUniform Electronic Transactions Act (UETA)
References
Case No. ADJ16597333
Regular
Aug 12, 2025

TYSON PEREZ vs. CHICAGO DOGS, LIBERTY MUTUAL INSURANCE COMPANY; HOUSTON ASTROS, ACE AMERICAN INSURANCE COMPANY/ CHUBB

The Workers' Compensation Appeals Board issued an en banc opinion to grant reconsideration regarding a jurisdictional dispute involving applicant Tyson Perez. Defendant Chicago Dogs sought reconsideration of a WCJ's finding of personal jurisdiction, arguing their witness was improperly denied electronic testimony crucial for presenting evidence. The Board found the denial of electronic testimony without due process to be an error, emphasizing the policy favoring adjudication on merits. Therefore, reconsideration was granted, and a final decision is deferred for further review.

WORKERS COMPENSATION APPEALS BOARDEN BANCPETITION FOR RECONSIDERATIONPERSONAL JURISDICTIONELECTRONIC TESTIMONYDUE PROCESSFAIR HEARINGSUBSTANTIAL JUSTICELIBERAL PLEADINGDISCOVERY
References
Case No. ADJ10711762 ADJ10901794
Regular
Dec 24, 2019

DAVID YEREMYAN vs. COMFORT KEEPERS, INSURANCE COMPANY OF THE WEST

The Workers' Compensation Appeals Board granted reconsideration of a WCJ's decision that a lien claimant's Labor Code section 4903.8(d) declaration required a "wet signature" for validity. The Board found that an electronically signed declaration, submitted via JET filing, meets legal requirements and is attributable to the signatory. Therefore, the lien claimant's declaration was deemed validly filed on the date of electronic submission, not when the "wet signature" was later provided. The case was remanded to the trial level for further proceedings on the statute of limitations issue.

WCABPetition for ReconsiderationLien ClaimantLabor Code section 4903.8(d)Wet SignatureElectronic SignatureStatute of LimitationsEDEXISJET FilerEAMS
References
Case No. ADJ9249111
Regular
Dec 01, 2016

JERMAINE HILL vs. COCA COLA COMPANY, SEDGWICK CLAIMS MANAGEMENT SERVICES, INC.

This case involves a petition for reconsideration filed by Psychological Assessment Services (PAS) regarding a Workers' Compensation Appeals Board (WCAB) decision. The WCAB dismissed the petition as untimely. California law requires petitions for reconsideration to be filed, meaning received by the board, within 25 days of service by mail, with electronic filing deadlines also strictly enforced. In this instance, PAS electronically filed its petition one day after the jurisdictional deadline, rendering it void.

Petition for ReconsiderationUntimely FilingDismissalJurisdictional Time LimitService by MailElectronic FilingWCABWCJLabor Code SectionsCalifornia Code of Regulations
References
Case No. ADJ7484646
Regular
Apr 26, 2012

CHRISTINE SPIGNER vs. NEC ELECTRONICS, MITSUI SUMITOMO MARINE MANAGEMENT

The Workers' Compensation Appeals Board dismissed Christine Spigner's Petition for Reconsideration in the case against NEC Electronics and Mitsui Sumitomo Marine Management. The dismissal was based on the petition's failure to be verified, a violation of Labor Code section 5902. This procedural defect rendered the petition invalid. The Board's decision was consistent with established precedent regarding unverified petitions.

Petition for ReconsiderationVerifiedLabor Code section 5902DismissalWCJ ReportWorkers' Compensation Appeals BoardADJ7484646SpignerNEC ElectronicsMitsui Sumitomo Marine Management
References
Case No. ADJ195920 (FRE 0239875) ADJ8378632
Regular
Apr 15, 2015

Darrell Coufal vs. Osmse, Ace America

The Workers' Compensation Appeals Board (WCAB) granted the applicant's Petition for Removal regarding the WCJ's February 2, 2015 decision. The WCAB affirmed the original decision but amended it to allow Ms. Cheryl Jolley Smith the opportunity to reconstruct the file electronically. If electronic reconstruction is not possible, she is ordered to subpoena the records at her own expense. This order ensures the integrity and accessibility of the case file.

Petition for RemovalDecision After RemovalWorkers' Compensation Appeals BoardWCJ's reportreconstruct the filesubpoenaing recordsexpenseelectronic reconstructioncase fileapplicant
References
Case No. ADJ9837116, ADJ9837115
Regular
Aug 10, 2018

EVERARDO OCAMPO SANCHEZ vs. MAJESTIC INTERIORS, STATE COMPENSATION INSURANCE FUND

The Workers' Compensation Appeals Board (WCAB) rescinded a prior order dismissing a lien claimant's liens by operation of law. The WCAB found that a corporate signature on a Labor Code section 4903.05 declaration, when filed electronically, is permissible and does not necessarily render the declaration defective. The Board clarified that electronic signatures by entities are valid for these declarations, and the case was returned for a new decision on the validity of the declaration and other issues.

Workers' Compensation Appeals BoardLien ClaimLabor Code Section 4903.05DeclarationDismissal by Operation of LawElectronic SignatureJET FilerEAMSDigital SignatureUETA
References
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